Tax Treaty Aspects of Corporate International Tax Structuring

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Tax treaties play an important role in the international tax structuring of multinational groups. This course examines the interplay between domestic tax law and tax treaties on cross-border business activities, the role of tax treaties in mitigating double taxation, in facilitating international tax structuring opportunities and in mitigating outcomes of tax structures which are considered to be too aggressive. The course also addresses eligibility to tax treaty benefits in view of recent developments. Tax treaty interpretation issues and disputes that are associated with the use of tax treaties in such corporate tax structuring practices are also addressed. These issues are explained with illustrative examples and interactive questions.

Topics Covered

  • Applying tax treaties to cross-border business activities
  • The role of tax treaties in international tax structuring
  • Eligibility to treaty benefits
  • Interpretation and dispute resolution

Learning Objectives

After completing this course, you will be able to:

  • Define the role and impact of domestic tax laws and tax treaties in cross-border business activities
  • Assess the importance of tax treaties for double taxation avoidance and their potential role in the mitigation of single taxation
  • Identify international tax structuring opportunities under tax treaties
  • Apply the conditions for the application of tax treaties and eligibility to tax treaty benefits when they are applied in a different context 
  • Differentiate different treaty anti-abuse rules and their scope of application 
  • Identify sources of disputes under tax treaties and how issues of interpretation arise
  • Determine the processes of resolving disputes and mutual agreement procedures 

Delivery method and Core Study Time

Online (QAS self-study)

Consists of four modules of approx. 1-hour video lessons each and case assignments that help apply knowledge in practice. A final assessment is also included to test your overall understanding.

Field of study


Who should participate

This course will benefit tax professionals working in multinational groups, tax and legal advisory firms and governments, including:

  • In-house tax professionals and advisers responsible for the structuring of corporate group entities and their associated tax affairs
  • Legal professionals assessing the risk of tax controversy associated with corporate tax structures
  • Government officials reviewing and auditing multinational groups and their corporate tax structuring practices 


This is an intermediate-level course. Participants in this course are expected to have at least 3 to 5 years of experience in international tax and are familiar with the key concepts of international tax law.

Components of Training and Study time

This online course is divided into four modules (each consisting of videos of approximately 1 hour per module), case assignments and recommended reading materials.

Access to the online course is granted for a period of 2 months from the date of ordering.

Continuing Professional Education (CPE)

International Online Tax Courses in many cases qualify for CPE credits pursuant to the rules of a number of professional associations other than those listed above. Participants are encouraged to check with their professional and/or national associations to determine eligibility in this respect.

International Bureau of Fiscal Documentation (IBFD) is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of CPE on the National Registry of CPE Sponsors. State boards of accountancy have the final authority on the acceptance of individual courses for CPE credit. Issues regarding registered sponsors may be submitted to the National. Registry of CPE Sponsors through its website: Recommended NASBA CPE credits for this course is: 7

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